Where a transfer is to be treated as one on
‘tax-neutral’ terms, the transfer is regarded for this
purpose as not involving any realisation of the asset by the
transferor, nor any acquisition by the transferee.
There is then a ‘stand in shoes’ approach such
that the transferee is treated as having held the asset throughout,
and having done all the things in relation to the asset as were in
fact done by the transferor.
In particular this means the transferor inherits the
transferor’s tax cost for the asset (see
CIRD12720), and all such debits and
credits as have been brought into account under Schedule 29 by the
transferor are treated for this purpose as though they had been
brought into account by the transferee.
